Laserfiche WebLink
<br />Yankee Gulch lease area (see Figure 3 of the Draft Area Permit). The <br />data indicate that the water quality in the B-Groove portion of the Lower <br />Aquifer meets the USDW quality standard identified on pages 5 and 6 of <br />the Statement of Basis. The water quality reported by American Soda of <br />readings greater than 10,000 mg/I TDS are from the A-Groove and are <br />not representative of the empirical data provided for the B-Groove in the <br />attached tables. <br />I believe several actions need to be addressed regarding the above issue. <br />The first is, how should the permit be modified to address this change in <br />assumptions regarding Lower Aquifer water quality? To address this <br />issue, I believe separate monitoring wells must be included for both the <br />A- and B-Groove portions of the Lower Aquifer. Without monitoring wells <br />in both aquifers, the EPA will not have sufficient data to protect the B- <br />Groove aquifer, or about 800 feet of aquifer storage above the mining <br />zone which appears to have USDW quality water. Also, the well <br />completion process may need to be strengthened for the portion of the <br />wells extending through the Lower Aquifer. Second, the EPA should more <br />carefully verify the data and assumptions that were submitted by <br />American Soda. It appears that the current submittal is flawed and must <br />be more carefully reviewed in the context of the empirical data being <br />obtained from the Test Mine Plan monitoring effort. Monitoring data are <br />available from the BLM regarding this issue. Finally, the potential threat <br />to USDW (utilizing criteria in 40 CFR para. 144.3) should be reevaluated <br />given the greater proximity and quantity of USDW water to the mining <br />area. <br />Page 6: The Statement of Basis and Draft Permit require only two seasons of <br />monitoring to establish a baseline for the two springs near the project <br />area. This is not sufficient to characterize the full range of flow regimes <br />for the two springs. At lease one baseline sampling should be conducted <br />in each season, winter, spring, summer and fall. Operations will be year <br />round and the baseline and future sampling should be conducted at least <br />quarterly at these springs to ensure that degradation or alterations in <br />spring activity will be discernable at first occurrence. <br />Page 13: Please refer to the comment above (page 4) regarding the adequacy of <br />formation testing. As noted in that comment, the testing thus far does <br />not appear to provide an adequate data base for determining the <br />performance of the formation under the proposed mining method. <br />Pp. 17/18: I am concerned that EPA is authorizing the use of ten sources of fluids <br />{see pages 17 and 18 of the Statement and page 16 of the Draft Area <br />Permit) for which is does not have any control over the content of the <br />fluids. No testing of these various fluids is required so how could any <br />entity determine whether hazardous waste (as defined in 40 CFR 261.3) <br />has been incorporated into the injection fluid. It would seem appropriate <br />3 <br />